giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…Giuffre changed course. With this lawsuit producing no more money,
Ms. Giuffre wants to use its information to profit from generating new lawsuits—and media
coverage—through her well-worn strategy: Accuse a prominent person of participating in
Epstein’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.13_1
3 pg
…in defendant’s possession.
Setting aside that this is not what the RFP asked for, that too would entail an
extraordinary and unreasonable amount of time and money, since plaintiff’s
various names are guaranteed to have thousands of hits…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.5_1
3 pg
…in defendant’s possession.
Setting aside that this is not what the RFP asked for, that too would entail an
extraordinary and unreasonable amount of time and money, since plaintiff’s
various names are guaranteed to have thousands of hits…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…be a witness: he was the one who initiated contact with Brad Edwards
after reading about the lawsuit, asked to be a witness in this case, hopes to make money from this
4
Doc. #62 & Tr. of Hearing of Mar…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…his declaration is not “self-serving.” In any event, calling a
declaration “self-serving” is a legal canard. There is nothing improper even for litigants suing for
money, such as plaintiff, to submit “self-serving” declarations so long as they…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…no such claims. Remarkably, Plaintiff still refuses to disclose both the
Settlement Agreement and the vast sum of money she has already obtained from Jeffrey Epstein related to her
claims, despite their much greater relevance to this action. A further…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…and Casey Sullivan, Alan Dershowitz
Extends Truce Offer to David Boies Amid Bitter Feud.
UPDATE (4/12/2016, 10:45 a.m.): Did money change hands as part of this settlement? See
Vivia Chen, Did Dershowitz Pay Big Bucks to…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…witnesses Epstein, Marcincova
and Kellen. She fails to advise the Court that Ms. Maxwell has been “forced” to expend great
time, money and resources to serve Plaintiff’s own mother, father, former fiancé and former
boyfriend. As described before, the…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…purpose.
Without waiting such objections, Ransome is not in possession of any documents
responsive to this request.
13
15. All Documents reflecting any money, payment, valuable consideration or other remuneration
received by You from Jeffrey Epstein or any person known…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…objections, Ransome is not in possession of any documents
responsive to this request.
13
Case 1:15-cv-07433-LAP Document 1332-8 Filed 01/08/24 Page 15 of 27
15. All Documents reflecting any money, payment, valuable…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…2016 Correspondence. Ms. Giuffre’s attorneys have expended considerable sums of
money on the retention of an outside e-discovery management company to assist in a thorough
collection, review, and production of responsive documents to ensure compliance with her
discovery…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…heard, Dershowitz settled the underlying
litigation. Dershowitz has insisted upon keeping confidential the monetary settlement that
resolved the claims against him.23 The trial court declined to retain jurisdiction to hear Ms.
Giuffre’s sanctions claims after the settlement. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.422.0
8 pg
…Ghislaine Maxwell request that this Court compel Plaintiff
to produce the Settlement Agreement between her and Jeffery Epstein and all associated
documents concerning her receipt of money from that settlement within two business days of the
Order on this Motion…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…not have been submitted to
the Court. The declarant suffered multiple felony convictions and had been involved in attempting
to obtain money from one of Plaintiff’s lawyers in exchange for alleged evidence. These issues
were briefed in various undecided…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…purpose.
Without waiting such objections, Ransome is not in possession of any documents
responsive to this request.
13
15. All Documents reflecting any money, payment, valuable consideration or other remuneration
received by You from Jeffrey Epstein or any person known…
giuffre-maxwell
1320-28
32 pg
…be a witness: he was the one who initiated contact with Brad Edwards
after reading about the lawsuit, asked to be a witness in this case, hopes to make money from this
4
Doc. #62 & Tr. of Hearing of Mar…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…filing of
tax returns, savings, checking, or other bank deposits, investment deposits, ownership of a safe
deposit box, cash on hand and pending legal actions for money. Evans v. Celise, No. 92-civ-
8430 (PKL), 1994 WL 185696, at *2 …
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…filing of
tax returns, savings, checking, or other bank deposits, investment deposits, ownership of a safe
deposit box, cash on hand and pending legal actions for money. Evans v. Celise, No. 92-civ-
8430 (PKL), 1994 WL 185696, at *2 …
giuffre-maxwell
gov.uscourts.nysd.447706.941.0
6 pg
…be the best of
disinfectants; electric light the most efficient policeman.” L. Brandeis, Other People’s Money and
How the Bankers Use It 62 (National Home Library Foundation ed. 1933), as quoted in Igneri v.
Moore, 898 F.2d 870…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…and we won't be able to see until then if she's paid
15 taxes on all the money and gifts and in-kind payments from
16 Epstein that she's received or has kept that away from the…
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